During an audit of process safety performance, besides interviewing the staff responsible for the MOC program, which verifications should be performed?

• A. The procedure clearly defines what constitutes change
• B. The procedure assures that the authorization requirements for the change are addressed
• C. Both A and B
• D. Neither A nor B

Answer: (C)

The key idea here is that an effective MOC program rests on two essential controls: a clear definition of what counts as a change, and explicit authorization requirements for that change. Verifying both ensures that changes are consistently identified and properly reviewed before they impact the process safety landscape.

If the procedure doesn’t clearly define what constitutes a change, people may treat modifications inconsistently, leading to unrecognized or unmanaged risks. Conversely, if the procedure doesn’t specify authorization requirements, changes could be made without the necessary risk assessment, approvals, or documentation, allowing hazards to slip through the cracks. Together, these verifications confirm that changes are both properly identified and adequately controlled, which is fundamental to managing process safety hazards during audits.

In practice, you’d examine the written MOC procedure to confirm it explicitly defines what constitutes a change and to verify there are documented authorization steps, including who can approve changes, what risk evaluations are required, and how approvals are recorded before implementation.